Express, Implied, or Equitable Release of Rights), Reservation of Right to Add Additional Affirmative Defenses. As a fourteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that the action of Defendants is barred by the applicable statutes of limitations, including, but not limited to, California Code of Civil Procedure Sections 338(a), 338(d), 339(1) and 343; 343; Commercial Code Sections 2725(1) and 2725(2); and Civil Code Section 2079.4. II. affirmative relief and sue on the basis of any cause of action that may be appropriate in a particular situation. Here's an example. Providing quality ADA Defense, Business & Real Estate Services throughout the United States for over 40 years. Here is a list of affirmative defenses to raise in answer to complaint. Affirmative Defenses. 11 0 obj Therefore, any possible defense you might want the court to consider at trial should be in your Answer. by the defendant. Complaint Headings. A Practice Note outlining how to answer a complaint in California superior court. stream In addition, more detailed descriptions and explanations of each defense is forthcoming. %PDF-1.4 % (example only). endstream Demand for jury trial. These are called "affirmative defenses." There many affirmative defenses . 8. Defendant admits the allegations of paragraph 2. That Plaintiff take nothing by reason of the unverified Complaint herein, and that these answering Defendants be dismissed hence; 2. FindLaw Codes may not reflect the most recent version of the law in your jurisdiction. 10. cHusuwbY2v1js9Ilzz/TT or according to the information and belief of the defendant, even if the complaint 965 0 obj <>/Filter/FlateDecode/ID[<1EFA76720BFB1441B2325E398AE73AC4>]/Index[945 53]/Info 944 0 R/Length 95/Prev 371620/Root 946 0 R/Size 998/Type/XRef/W[1 2 1]>>stream endobj ANSWER TO COMPLAINT SEVENTH AFFIRMATIVE DEFENSE Plaintiff's claims are barred by the . 9. Orange County. 9. In order to raise all possible defenses in your answer, you need . An explanation of 'properly served' can be found by searching 'How will I know I am being sued or taken . Waiver. 13 0 obj In this situation, you can use a combined response. As a third, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that they have incurred damages by reason of Plaintiffs conduct and that it has the right of offset of any amount of monies owed to Plaintiff by way of damages. An affirmative defense is an argument that Plaintiff's claim should fail for some procedural or legal reason. endobj Document collections are now available as non-refundable purchase items with new pricing. Search Instructions. In the Answer, Defendant states "The Complaint, and each and every cause of action contained therein, fails to state facts sufficient to constitute a cause of action against this answering Defendant, or at all." there is no deal . N}}Yp*KtXG2/>kh %DP5N74F{"O*O N0Ys Although this blog post will refer to an answer to a complaint the same principles discussed here also apply to cross-complaints. In the Answer, all defenses to the allegations of the complaint must be raised, and all facts essential to supporting a particular defense must be included. %%EOF (c) Affirmative relief may not be claimed in the answer. Readers should not act upon this information without seeking professional counsel. VERIFED ANSWER WITH AFFIRlVlATIVE DEFENSES The Respondents respectfully submit the within Verified Answer on a Pro Se basis to the compiailll dated April 1. 11. Legal Resources dq4/K&!SNL"Qh*r]h. Fax. The next part of your Answer on page 3 is where you list your Affirmative Defenses. San Jose, CA 95113 If you are answering a verified complaint in California you must admit or deny each and every paragraph of the complaint, and you must also include a verification signed by the defendant or defendants or their attorney stating that they have read the answer and everything contained therein is true and correct to the best of their knowledge. For such other and further relief as the Court may deem just and proper. c/*Z Z'h&U0ZM41\44mFx#[qQ2&?)DatN!Q. 83.232 (5). As a fifth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants are informed and believe, and on such information and belief, allege that by reason of Plaintiffs conduct which constitutes a breach of contract, tortious conduct, waiver, unclean hands, and laches, Plaintiff is estopped to assert any right of relief. hbbd```b``A$ The Leading Law Firm In The Nation For ADA Legal Defense, On Behalf of The Karlin Law Firm LLP | Jun 29, 2012 | Real Estate Disputes |. Click the on our main page to search for what you are looking for. Contact Us ********************************* 4. Many affirmative defenses are listed in Rule 94 of the . Without waiving any defenses, CSL asserts that MCS's Complaint fails to state a claim for which relief can be granted. They are currently arriving within 30 minutes of purchase. The sample includes several affirmative defenses, brief instructions and a proof of service by mail.The author is a freelance paralegal who has worked in California and Federal litigation since 1995 and has used this sample for many years. Specifically, this Note explains how to respond to the complaint's allegations, assert defenses, compute and extend the time to answer, and serve and file the answer. The Complaint fails to state a claim upon which relief may be granted. endobj To James N. Pappas #6291873, Burke Costanza & Carberry LLP, NOW COMES the Defendant, WILLA DUNN . The Affirmative Defenses listed are those stated in . What follows is for discussion purposes only for review and consideration by and for liciensed Calfornia Defense lawyers, and should not be used in any particular matter or case. A negative defense is the specific denial of the material fact or facts alleged in the pleading . Posted on Jul 9, 2012. At its core, the Complaint centers on MCS's claim that CSL has breached the service contract between it and MCS. Attorneys or parties in California who wish to view a portion of a sample answer to a verified complaint for sale by the author can see below. AFFIRMATIVE DEFENSES 4.____ I received the Summons and Complaint, but it was not properly served. Ostling v. Loring (1994) 27 Cal.App.4th 1731, 33 ["Our system of code pleading requires only fact pleading. Just visithttp://freeweeklylegalnewsletter.gr8.com/for more information. Estoppel. Executed on August 8, 2008, at Los Angeles, California. 0 Riverside County. As a fourteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that the action of Defendants is barred by the applicable statutes of limitations, including, but not limited to, California Code of Civil Procedure Sections 338(a), 338(d), 339(1) and 343; 343; Commercial Code . 2:16-cv-00862-RGK-JC 8. In particular, if the complaint includes a misclassification claim, an affirmative defense alleging that plaintiffs were exempt under the applicable exemption should be included. C. Defendant has no information or belief that the allegations of paragraph 3 are true so defendant denies them. As a first, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiffs unverified Complaint, in its entirety, nor any purported cause of action set forth therein, allege facts sufficient to constitute a cause of action against these answering Defendants. The author is NOT engaged in providing any legal, financial, or other professional services, and any information contained in this blog post is NOT intended to constitute legal advice. ANSWER AND AFFIRMATIVE DEFENSES. Santa Monica, CA 90404 <>stream FIRST AFFIRMATIVE DEFENSE 2. 'GDoeIr*7IEm\+x#tG^}!B A5k}L6wS|-[kE\Uf5W;8H{z"5_^oq3)SiL?$x3F>? [>k +2!w+COZ99(]:'3W2p?a) 0D\7[g~jD7 h_L^(Cw:5Pfpbo^J07fX$ZBSH1E=L.RK}^E+C7APQXmHOSXvM5BnwV^XMScB26Q0;% 2U~f S0055dW?`mT\nx qJfc-7s4w%J1e-y)bwVgQrD_# 4Lp-{?%jRf:R-op%UO9E)#eTDW$oS*S~L2e2RjByW*fdM)B"&H[VYH3ttqh3Xu7&,`53~!xgGS8Ak TfA2 WHEREFORE, these answering Defendants prays for judgment as follows: 1. 2 0 obj It takes little effort, or time, to deny the affirmative defenses. 22 Fifth Affirmative Defense 23 (Primary Jurisdiction) 24 The primary jurisdiction doctrine bars, and/or requires suspension of the adjudication of, 25 plaintiffs' Complaint and its cause of action for declaratory relief. However, it is perpetually non-exhaustive as new affirmative defenses are being asserted in court almost every day. The Complaint in its entirety fails to state facts sufficient to constitute a cause of action against these Defendants. IV. This sample answer to personal injury complaint in California is used by a defendant to answer an unverified personal injury complaint. 0 (TYPE OR PRINT NAME) (SIGNATURE OF DEFENDANT) UD-105 [Rev. This is due to the fact that an answer that contains nothing but "boilerplate" affirmative defenses is vulnerable to a demurrer on the grounds that the answer fails to state facts sufficient to state any defenses to the complaint. endstream endobj startxref endobj (2) Defendant includes a person filing an answer to a cross-complaint. endstream This sample motion to strike an answer to a complaint for California is made pursuant to Sections 435-437 of the Code of Civil Procedure. 1 0 obj (TYPE OR PRINT NAME) (SIGNATURE OF DEFENDANT) UD-105 [Rev. California. 5. )yeJ0/EY'U9/L(Kk 7. a. c. d. Description of facts is on MC-025, titled as Attachment 3. l. Defendant vacated the premises on The fair rental value of the premises alleged in the complaint . In Florida this is generally required. 2. 5. Affirmative Defenses to PAGA Claims Sample Template. The ADA Americans with Disability Act, or Unruh Act violations or non-compliance claimed and modifications requested are not Readily Achievable and the building was build _______ before the enactment of the various ADA laws and regulations were enacted. XVV7Jg:GZ;84? General . _______________and______________; and DOES 1 through 5, inclusive, ASSIGNED FOR ALL PURPOSES TO THE HONORABLE_____________. admitted. (Jones v. Grewe (1987) 189 Cal.App.3d 950, 954.) 4 0 obj This is not to be used in all matters or cases, and each matter or case is different. 9. or if it is not a true affirmative defensea defense which, for example, demonstrates only that the plaintiff has not met her burden BSlPVP>]*,!B7D9](YozVC\'vr"#"#rt\~\ey2KqR!RMsede;"^\vqG]b.xYd#.GKpg(ZP.<7e)~a|rc 1T&AZ !\& . information or belief, with a general denial of all allegations not so denied or expressly Private message. ANSWER AND AFFIRMATIVE DEFENSES Defendant, PASCO TRAILS ASSOCIATION, INC. (the "ASSOCIATION"), through undersigned counsel, hereby responds to Plaintiffs' Complaint, in like-numbered paragraphs, and states as follows: Parties and Jurisdiction 1. (9]{`K-6BBH*'dVS@#Trg/iGdMA!y?eU?o>(HtTgztJTW[mfHKy@_ z <>stream x+ Acknowledged that Plaintiffs so allege. FindLaw.com Free, trusted legal information for consumers and legal professionals, SuperLawyers.com Directory of U.S. attorneys with the exclusive Super Lawyers rating, Abogado.com The #1 Spanish-language legal website for consumers, LawInfo.com Nationwide attorney directory and legal consumer resources. Additionally, failure of the tenant to comply will result in the landlord receiving an immediate default for possession without further . <> DEFENDANT'S ANSWER TO PLAINTIFF'S COMPLAINT Defendant United Parcel Service, Inc. (hereafter "UPS" or "Defendant"), by and through its counsel, Reed Smith, LLP, hereby answers the Complaint of Plaintiff Michael MacDonald ("Plaintiff") and asserts its Affirmative Defenses as follows: INTRODUCTION AND BACKGROUND STATEMENT 1. J0pe/x9VP&j?7b . C/A No. An affirmative defense may be insufficient as a matter of law or as a matter of pleading. Page 2 of 2. Admissions or denials generally consist of the following: A. with Section 90) of Chapter 5.1 of Title 1 of Part 1, the denial of the allegations shall be made positively or according served with a complaint, or counter-complaint or cross-complaint) or if you are the recipient of a notice of adverse action in public employment or you received an accusation seeking to revoke your license - you . You will likely need to file more than once to win your case in court. . Or, in the alternative, it will serve as a check-list to review before finalizing your answer or responsive pleading. endobj <>stream 7. This is sort of a grandfather or grandfathered in defense, but not exactly the same as there are many factors to consider. 2. endstream endobj startxref STATUTORY CLAIMS UNDER THE INSURANCE CODE & DPTA There are several claims that are commonly Note that this rule only applies to unlimited civil cases, where the demand of the complaint exceeds $25,000.00. As to Paragraph 1 of the Complaint, Defendat admits the allegations contained in this Paragraph for jurisdictional purposes only, however, does not admit Plaintiff is entitled to the relief sought therein. endstream endstream 8 0 obj Sample Answer to Verified Complaint for California by Stan Burman on Scribd, To view more information on over 300 sample legal documents for California and Federal litigation visit:https://legaldocspro.myshopify.com/products. Hopefully, this list will assist you in brainstorming the defense of your case. Defenses are set forth by a defendant in his answer to the complaint. l"dngf DAVEY ROOFING, INC.'S ANSWER TO COMPLAINT OF WESTERN NATIONAL CONSTRUCTION FOURTEENTH AFFIRMATIVE DEFENSE The Complaint, and each cause of action thereof, fails to state a cause of action against Defendant for breach of warranty, expressed, implied or otherwise, because there is no privity between Plaintiff and this Defendant. It would take more time and effort to move to strike the defenses if they are not legally sufficient. service of process). UD-105 (Each defendant for whom this answer is filed must be named in item 1 and must sign this answer unless his or her attorney signs.) First Affirmative Defense. 14 0 obj 15. The Sample Answer, which is one form of Respose, to a ADA Lawsuit, Busienss, or Real Estate Lawsuit filed in a California Superior Court, or in the case of an ADA lawsuit, filed in part in Federal District Court for ADA claims. FREE STUFF. 4. COMES NOW XXXXXXX ("Defendant") answering the Complaint filed by XXXXXX alleging willful copyright infringement by responding as set forth below, and Defendant raises affirmative defenses as follows: JURISDICTION AND VENUE <>>> 2. The plaintiff has to prove his or her case against you, but you have to prove your affirmative defenses. As a sixth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants are informed and believe, and on such information and belief, allege that Plaintiff breached his contract, if any, with Defendants and by reason of such breach of contract, these answering Defendants has been excused of any duty it may have had to perform any obligation set forth in any agreement with Plaintiff, if there be such an agreement. Fax. 7)[>qaU26H/ 6 }J$Apu#4=1J Fp"6Q"Z How We Help 7/* [*(_RKTb.xsB-+LR;pqM3&p>Er}{czn7$z,`IS^o 84 0 obj <> endobj 93 0 obj <>/Filter/FlateDecode/ID[<68430C055B5D4B2283A7935E584E5DB5>]/Index[84 16]/Info 83 0 R/Length 62/Prev 670072/Root 85 0 R/Size 100/Type/XRef/W[1 2 1]>>stream As a thirteenth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiff did not reasonably rely upon any alleged misrepresentations or nondisclosures of material facts made by these answering Defendants; therefore, Plaintiff is barred from seeking any affirmative relief against these answering Defendants. QPy!dU]6D:Y_N4E9|SG mG-uwE>D(B3Hu6Fik/*8 %%EOF However, some of the affirmative defenses are more properly styled "additional defenses" where the plaintiff/claimant bears the burden of proving that the defense does not apply (e.g. Any allegations of the complaint that are not specifically denied are considered admitted so it is critical that all of the allegations of the complaint that can be truthfully denied are in fact denied. x+ See Code of Civil Procedure 430.80(b). to the information and belief of the defendant. Significantly, a pleading must allege facts and not mere legal conclusions. A California Court of Appeal ruled in the case of FPI Development, Inc vs. A1 Nakashima, (1991) 231 Cal.App.3d 367, 384 that the affirmative defenses alleged in an answer to a complaint must be pled in the same fashion, and with the same specificity, as a cause of action in a complaint. By reason of such waiver, these answering Defendants is excused from the performance of the obligation of the alleged contract. Please note that there will never be a case in which ALLof these defenses are appropriate. When drafting an answer, one must: (1) follow the local, state, and federal court rules; (2) research the legal claims in the adversary's complaint; (3) respond to the adversary's factual allegations; and (4) assert affirmative defenses, counterclaims, cross-claims, or third-party claims, if applicable. As a second, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that the action sued on herein is barred by the provisions of Civil Code Sections 1624(b), 1624(c) and 1624(d), in that the contract sued on is for the building and site remodeling, trade services, labor and materials of real property and is invalid unless subscribed by the party sought to be charged. Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, 2023 The Karlin Law Firm LLP All Rights Reserved, Disclaimer| Site Map| Privacy Policy |Business Development Solutions by FindLaw, part of Thomson Reuters, Sample General Denial Answer with Affirmative Defenses filed in California Superior Court or Federal ADA, Business or Real Estate Lawsuit with Affirmative Defenses. complaint:_____ 3. More and more plaintiffs' attorneys are bringing demurrers to the affirmative defenses in answers. 2 0 obj to the causes of action which they are intended to answer, in a manner by which they endstream Hj`L E Answer and Affirmative Defenses in response to Plaintiff's Complaint for Foreclosure of Mortgage (the "Complaint") and states: ANSWER 1. Richard Burman, Managing Partner 02Nov2020. endobj Can your hotels employees cause an ADA lawsuit? The author is . California-specific forms give you the option to admit (agree), deny (disagree), or deny because of a lack of sufficient information (I don't know). Make A Payment, Nurses, Midwives, and Psychiatric Technicians, Claimants Own Conduct, or By the Conduct of Its Agents, Representatives, and Consultants, Damages Were the Result of Unrelated, Pre-Existing, or Subsequent Conditions Unrelated to Defendant's Conduct, Doctrine of Primary or Exclusive Jurisdiction, Failing to Plead Fraud with Particularity, Failure to Act in a Commercially Reasonable Manner, Failure to Exhaust Administrative Remedies, Failure to State a Claim Upon Which Relief Can Be Granted, Failure to Take Advantage of Effective System to Report/stop Harassment (i.e. A note about Affirmative Defenses: An affirmative defense gives a reason why you may have done something that was alleged. This Note does not address specific issues regarding answers in . or by denial of certain allegations upon information and belief, or for lack of sufficient The sample requests that the entire answer be stricken as it is not verified, or in the alternative that all of the affirmative defenses contained in the answer should be stricken as they contain only immaterial allegations. 2 0 obj When an employer has been sued by a former employer under California PAGA claim, all the affirmative defenses must be alleged or waived at trial. San Diego County. paragraphs or parts of the complaint; or by express admission of certain allegations Plaintiff's claims are barred, in whole or in part . The danger of not denying is that the defenses are deemed admitted, making summary judgment even more difficult since you would have to . kzWzh*^ b!njO0nXHn=OKS -*x~Iy These demurrers are based upon the respective defendant's failure to state facts sufficient to constitute a defense pursuant to the requirements of California Code of Civil Procedure Section 430.20. You can deny and make the motion as well. ___ Plaintiff agreed to accept or accepted a lower amount to pay off the debt, but is now asking for more than the amount we agreed to. Section 83.232 (5) provides that failure of the tenant to pay the rent into the court registry shall be deemed an absolute waiver of the tenant's defenses to the commercial eviction action. ANSWER TO COMPLAINT AND AFFIRMATIVE DEFENSES. This is part of Vail Law's Litigation Checklist. Please verify the status of the code you are researching with the state legislature or via Westlaw before relying on it for your legal needs. x$NdciA[,"QwH2 _gor6oW^==f\W%^G>7;{q|!qB3G[:>:}LGd"a9Aw -J_~?:>=jH1fA" 7}msk}&|9AazsT0-X*R %J 6xjp5RNQN@ffSbS9Y?Y0ePK,Y 0iYgSp>&![+$Q#)m$"NEi }X * G68DdE*n~^ns.5I2q1X'ky|tAG*L$ jl(u*a,!qc\?&s /9Ynl8x4('O>`Axb,77O:dG1,Ss$XFQJ! 2011 (hereafter "Complaint"). We pay up to 30% referral fees to lawyers, and per CA Bar rules. 7 0 obj This list is long. The purpose of an affirmative defense is to give enough notice of your defenses so that Plaintiff and the Court understand your argument. hb```f`` @1V kJdaZhf N7 Most civil complaints in California are not verified unless there is a particular statute or code that requires that a particular cause of action be verified. You can and should attach the amended answer and affirmative defenses to your motion. However, neither the facts pled in the Complaint nor the text of the contract itself support such a claim. 13. Copyright 2023, Thomson Reuters. 3 1 2 3 4 5 6 7 8 9 10 11 12 13 14 15 16 17 18 19 20 21 22 23 24 25 26 27 28 . If you believe one is missing, please let us know by contacting usand it will be added. The materials and information contained in this blog post have been prepared by Stan Burman for informational purposes only and are not legal advice. %PDF-1.5 However I want to point out that any plaintiff can choose to verify their complaint. 8. 424.268.8818 Any other answer would be drafted in "pleading format." General Denial: The General Denial (PLD-050) contains a statement denying the truth of each and every allegation of the Complaint. and__________________ (hereinafter these answering Defendants), and answering the unverified Complaint on file herein for and on behalf of itself alone, answers Plaintiffs unverified Complaint as follows: Under and pursuant to the provisions of California Code of Civil Procedure, specifically, Section 431.30 thereof, these answering Defendants generally denies each and every allegation of said unverified Complaint, and the whole thereof, and each and every allegation of each and every cause of action alleged therein, and further expressly deny that as a direct or proximate result of any acts or omissions on the part of these answering Defendants, Plaintiff herein sustained or suffered injury or damage in the amount alleged in the unverified Complaint, or in any amount at all, or that Plaintiff has suffered injury or damage for any reason in the sums alleged in the unverified Complaint, or in any other sum or sums, or at all. ********************************* 1. No other pleadings shall 10 . You can also file a motion seeking to amend your answer. Do you want to use this article on your website, blog or e-zine? Parts of the form which follows has assisted lawyers with cases arising thoughout Claifornia, including Tustin, Irvine, Costa Mesa, Santa Ana, Garden Grove, Lake Forest, Mission Viejo, Los Angeles, San Diego, Tustin, San Bernadino, and Sacramento. <>stream If you do not raise your affirmative defenses you waive them in your litigation case. 1381 0 obj <>stream Tel. !CMSKVF RgIN}Jv ^~%aC5_M$84P$(^$_,&{A\Hx`Q5\/B_J%;)goX!5A/S>_"}? This sample answer to a verified complaint for California is used when the complaint is verified, or if the complaint is filed by a government entity. <>stream hb```c``c`d`db@ !&fQ#ghDj_rBRhc&UV1\#$GP}l+$ t3 $! endstream endobj 85 0 obj <> endobj 86 0 obj <>/ProcSet[/PDF/Text/ImageB/ImageC/ImageI]/XObject<>>>/Rotate 270/Type/Page>> endobj 87 0 obj <>stream him or her to answer an allegation of the complaint, he or she may so state in his In the Eleventh Affirmative Defense, Defendants assert that "the claims of the '949 Patent are invalid for failure to meet the requirements of the United States patent laws." Id., 95. For more information about the legal concepts addressed by these cases and statutes, visit FindLaw's Learn About the Law. San Bernardino County. In certain instances, an allegation in the Complaint may contain claims that are partially true and partially false. served with a complaint, or counter-complaint or cross-complaint) or if you are the recipient of a notice of adverse action in public employment or you received an accusation seeking to revoke your license - you have a right to raise affirmative defenses that would defeat the claims of the party raising the claims or taking the action against you. My column this month will discuss the 26 main "Affirmative Defenses" available to a landlord to defend against tenants' causes of action, the importance of filing a Cross-Complaint, and provide a brief update on payment of minimum wages to apartment managers. 8(c) requires a party to "set forth affirmatively . Some affirmative defenses are more like properly styled additional defenses, and the plaintiff-claimant has to prove that it doesn't apply. If the complaint is verified, unless the complaint is subject to Article 2 (commencing TermsPrivacyDisclaimerCookiesDo Not Sell My Information, Begin typing to search, use arrow keys to navigate, use enter to select. (example only). endstream endobj 946 0 obj <>/Metadata 72 0 R/Outlines 260 0 R/Pages 943 0 R/StructTreeRoot 315 0 R/Type/Catalog>> endobj 947 0 obj <>/ExtGState<>/Font<>/ProcSet[/PDF/Text/ImageC]/XObject<>>>/Rotate 0/StructParents 0/Tabs/S/Type/Page>> endobj 948 0 obj <>stream Dh" V HpX{@=F dT9 $6>d`bdhYH?k m Fax. Sacramento, CA 95814 (example only). [any] matter constituting an avoidance or affirmative defense." Consider each of the below affirmative defenses--does it potentially . 2. As an eighth, separate, and affirmative defense to the unverified Complaint on file herein, these answering Defendants allege that Plaintiff herein, and each and every cause of action contained in the unverified Complaint, is barred because Plaintiff has engaged in acts and courses of conduct which render him in pari delicto.

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